Abstract
To understand the difficult topic of the treatment choice of law relative to security interests and other liens in international bankruptcies, it is necessary to begin by examining some of the basic parameters of American bankruptcy law. A fortunate coincidence is that bankruptcy law is currently the subject of the American Law Institute's Transnational Insolvency Project. This Project - undertaken cooperatively with Canada and Mexico, the other signatory nations to the North American Free Trade Agreement ("NAFTA") - is designed to proceed in two phases. Phase I involves experts of each nation producing "an international text summarizing the domestic and international aspects of the insolvency laws and practices of that country." Once Phase I is complete, Phase II will involve an exchange of ideas among experts from the three nations relative to cooperation in international insolvencies.